Case Digest (G.R. No. 151245)
Facts:
Ken Martin Clemente, Charlie Clemente III, assisted by their parents and natural guardians Charles L. Clemente, Jr. and Lorena P. Clemente, petitioners, vs. Antonio Razo, Elma Razo and Fatima Razo-Galias assisted by her husband Manuel R. Galias, respondents, G.R. No. 151245, March 04, 2005, the Supreme Court Third Division, Garcia, J., writing for the Court.The dispute concerns a 216-square-meter parcel in Legazpi City originally covered by Original Certificate of Title (OCT) No. 30 issued on March 24, 1966 in the name of Antonia Alaurin pursuant to a Miscellaneous Sales Patent. Several actions arose over the property: Civil Case No. 4391 (Antonia Alaurin v. the Yaptengcos) for recovery of possession; Civil Case No. 4412 (the Yaptengcos v. Antonia Alaurin) which was withdrawn and dismissed on February 7, 1975; and Civil Case No. 5595 (the Yaptengcos seeking annulment of the Miscellaneous Sales Patent). During the pendency of these suits Antonia and her children executed a Deed of Extrajudicial Partition and Sale (March 14, 1976) selling the land to Eugenio Razo, predecessor-in-interest of the respondents; that sale was not registered.
After consolidation of some of the earlier cases and a compromise recognizing Antonia as owner, in 1992 Gregoria Yaptengco Keh successfully petitioned the Regional Trial Court for issuance of an owners duplicate of OCT No. 30, supported by an affidavit of an alleged daughter, Adelina Alaurin; the petition was granted on August 24, 1992, OCT No. 30 was cancelled, and Transfer Certificate of Title (TCT) No. (P) 911 issued to Gregoria. On September 18, 1992 Gregoria sold the land to petitioners Ken Martin and Charlie (minors), represented by their mother and natural guardian, Lorena P. Clemente; the sale was registered and TCT No. (P) 914 was issued on September 30, 1992.
On January 17, 1996 respondents, as successors-in-interest of Eugenio Razo, filed with the Regional Trial Court (Legazpi City, Branch 2) Civil Case No. 9170 for annulment of title and/or reconveyance against the petitioners. The trial court, by decision dated January 21, 1997, found for the petitioners and declared them innocent purchasers for value. The respondents appealed to the Court of Appeals (CA-G.R. CV No. 56367). The Court of Appeals, in a decision dated August 10, 2001, reversed the trial court, held that irregularities shown on the reconstituted OCT No. 30 should have put the buyers on guard, nullified TCT No. (P) 914 and the deed of sale, and ordered reconveyance; i...(Subscriber-Only)
Issues:
- Did the Court of Appeals err in holding that petitioners were not innocent purchasers for value?
- May the Supreme Court review the conflicting factual findings of the trial court and the Court of Appeals i...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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